Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Bluestones Group’s slavery and human trafficking statement for the financial year ending 31 October 2019. This Statement has been approved by the Board of Directors of Bluestones Investment Group Limited which is the parent company of the Bluestones Group. Further information regarding the Bluestones Group is available at www.bluestonesgroup.co.uk.

The Bluestones Group does not believe there is any place in today’s world for slavery and human trafficking and in making this statement commits to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our businesses.

We are committed to evolving our practices through all our group companies to combat slavery and human trafficking and to encourage the same principles and standards from our supply chain and business partners.

No breaches of the Modern Slavery Act 2015 were reported in 2018 or have been previously.

Our Company Structure

Operating primarily in the UK, Bluestones Investment Group (Bluestones Group) employs over 200 people across 19 locations. Bluestones Investment Group is a human capital investment company, with the subsidiary businesses within the Group’s portfolio being made up of recruitment businesses, staffing service companies and related workforce solutions providers.

This statement applies to the Bluestones Group and its subsidiary companies, detailed below.

Bluestones Group subsidiary companies

APEX

Bluestones Medical

Bluestones One

Bluestones Staffing

Chad Harrison

Cogent Staffing

Connex Education

Harrison Sands

MEP Resourcing

NC Associates

NWP Resourcing

Paragons Accord Recruitment

Recruitment Funding Solutions

Recruit Ready

Recruitment Industry Benchmarking

Recruitment Training Group

The Classroom Partnership

The Teacher Training Partnership

The NQT Partnership

The International Teaching Partnership

Our online portfolio – available HERE – provides more information about each of these businesses within the Group.

Our supply chain

Bluestones Investment Group takes its responsibility for ensuring the risk of modern slavery and human trafficking is minimised across its supply chain. It achieves this through a combination of due diligence questionnaires for all suppliers and annual supplier audits. The Group expects its staff to report concerns of non-compliance, no matter how trivial, in line with the established policies and procedures.

Policies on modern slavery

Bluestones Investment Group has a clearly defined Modern Slavery Policy, which can be read in full HERE. This policy is regularly updated to reflect best practice methodologies, and subsequently approved at Board and/or Director level.

Our modern slavery policy reflects the Company’s commitment to acting with integrity in all its relationships and has implemented adequate policies, procedures and systems to ensure that slavery and human trafficking is not taking place.

Due diligence processes

In order to identify and mitigate the risks associated with modern slavery and human trafficking, Bluestones Investment Group has adopted the following processes:

We’ve reworked our supplier appraisal questionnaire to include unambiguous questions regarding a supplier’s compliance (with modern slavery and human trafficking legislation) and their policies and processes.

We review our supplier appraisal questionnaires on an annual basis to ensure continued compliance.

We conduct internal audits on our recruitment process (and those of our subsidiaries) to ensure that we only engage eligible workers for agency work.

We expect the suppliers we work with to have anti-slavery and human trafficking policies and processes that cover the subsequent relationships with their suppliers as it is not practical for us to influence and have a direct relationship with all levels of the supply chain.

Risk assessment

With many of the subsidiary companies within Bluestones Investment Group placing personnel into companies on a temporary, contract or permanent basis, we appreciate the importance of robust operational practices. Through the aforementioned due diligence processes, supplier audits and questionnaires, and internal policies and staff training, we act to minimise the risk of individuals being placed into any form of slavery.

Checks are also undertaken to verify and identify where agency workers may be sharing bank accounts, addresses and telephone numbers which may be a risk indicator.

Bluestones Investment Group will continue to assess the risks associated with modern slavery and human trafficking and aim to fully understand other indicators of modern slavery.

Measuring effectiveness

Through regular monitoring, audits and assessments we measure the effectiveness of our risk control measures to ensure that slavery and human trafficking is not taking place in our business, our subsidiary businesses or our supply chains.

100% pass rate when reviewing recruitment activities and their compliance with agreed modern slavery processes.

Training for staff

With such a clear focus on maintaining 100% compliance with modern slavery and human trafficking legislation, it is essential that the people within our business receive adequate training and information. We provide information on this legislation and our policies and processes via the Group’s Intranet system and through induction and regular training updates.

Employees, workers, business partners and customers are encouraged to report any concerns that may give rise to a risk of modern slavery or human trafficking. The Group’s Whistleblowing Policy is designed to make it easy for disclosures to be made without fear of retaliation. The Group’s Head of Legal, a practising solicitor, is the Whistleblowing Officer. In circumstances which prevent independent consideration of disclosures internally the Company’s auditors or external solicitors will be instructed.

Employees are advised on how to report any concerns they have associated with modern slavery and trafficking.

Related policies

Ethical Trading Policy

Bluestones Group and its subsidiary companies recognise that our commercial activities have the potential to impact on our suppliers and our locality. As a socially responsible small business our suppliers, local community and customers have a right to expect:

All workers involved in the delivery of services provided by Bluestones Group and its subsidiary companies are treated with full consideration to their basic human rights.

Bluestones Group and its subsidiary companies act in an ethical manner above and beyond basic legal requirements.

We are committed to implementing the principles of the Ethical Trading Initiative Base Code.

Code of Practice

This Code of Practice applies to:

Staff directly employed by Bluestones Group and its subsidiary companies on temporary, contract or permanent contracts.

Staff employed or provided by contractors or employment agencies to work on company premises or to undertake work for or on behalf of Bluestones Group and/or its subsidiary companies.

Employment Is Freely Chosen

No forced, bonded or involuntary labour shall be used.

Staff are not required to lodge deposits or identity papers with us.

Staff are free to leave Bluestones Group and its subsidiary companies after reasonable notice.

Working Conditions Are Safe and Hygienic

Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Staff receive health & safety information.

Staff have access to toilet facilities and drinking water.

The workforce has a published Health & Safety Policy.

Child Labour Shall Not Be Used

There shall be no recruitment of child labour.

Children or persons under 16 are not employed at any time, day or night.

Young persons under 18 shall not be employed at night or in hazardous conditions. Living Wages Are Paid

Staff pay rates are equal to or above the national legal minimum standards.

Staff are given information about their employment conditions in respect to wages.

No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions are provided for each pay period.

Staff are given clearly understandable written terms and conditions of employment that details the employment relationship and the respective obligations of the employee and employer.

Working Hours Are Not Excessive

Staff are not forced to work in excess of 48 hours per week, a voluntary opt-out agreement is available for those wishing to work in excess of 48 hours per week.

No Discrimination Is Practised

There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, marital status, sexual orientation, union membership or political affiliation.

Opportunities for personal and career development are equally available to all employees. No harsh or inhumane treatment is allowed

Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proved.

No Child Labour Policy

Introduction

The foundation of the Bluestones Group’s ‘No Child Labour Policy’ is based on the Company’s commitment to find practical, meaningful and culturally appropriate responses to support the elimination of such labour practices. It has been formulated in consideration with the acts. It, therefore, endorses the need for appropriate initiatives to progressively eliminate these abuses.

Policy

Bluestones Group and its subsidiary companies do not employ any person below the age of eighteen years at the workplace and prohibits the use of child labour and forced or compulsory labour in all of its businesses and operations. No employee is made to work against his/her will or work as bonded/forced labour, or subject to corporal punishment or coercion of any type related to work.

Implementation

This policy is publicly available throughout the Company and clearly communicated to all employees in a manner in which it can be understood through induction programmes, Intranets and policy manuals. The implementation of the policy is the responsibility of the Group’s human resources department, who do not permit minors to enter the workforce. There is zero tolerance policy towards its breach. Employment contracts and other records, documenting all relevant details of the employees, including age, are maintained by the Company and/or its subsidiaries and are open to verification by any authorised personnel or relevant statutory body.

Monitoring & Audit

Preventing Hidden Labour Exploitation Policy

Policy Statement

Bluestones Group and its subsidiary companies commit to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is an abuse of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as the forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims if they perceive of themselves as such, reluctant to come forward.

Policy Commitments

We shall:

Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.

Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. We will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.

Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.

Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.

Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Labour Abuse Authority and police if Modern Slavery is suspected.